Greece’s Independent Authority for Public Revenue (AADE) is rolling out a plan for the express settlement of thousands of pending tax cases set to expire at the end of the year, aiming to eliminate any risk of revenue loss for the public treasury. According to reports, the push will focus primarily on income tax, VAT, and property-related cases, with audit services ordered to prioritize high-value files — particularly those showing indications of undeclared income or unjustified accumulation of wealth. A central tool in these audits will be the Bank Account and Payment Registry System, which will be used to cross-reference bank transactions against declared income.
Read also: Tax refunds: 130,000 taxpayers yet to receive €190 million — why the money remains blocked
AADE: Which cases are racing toward the statute of limitations
Specifically, the following categories of cases are in the crosshairs of the tax audit services:
- Cases involving businesses and self-employed professionals operating under the electronic invoicing system through a registered provider, which are subject to a three-year statute of limitations. For tax year 2022, the deadline falls on December 31, 2026.
- Income tax and VAT cases for the year 2020, subject to the standard five-year statute of limitations. The deadline is calculated from the end of the year in which the relevant return was due. For returns relating to 2020 that were filed on time, the tax authority’s right to assess taxes expires on December 31, 2026. Bank transactions from 2020 fall into the same category, while those from 2019 and earlier are generally considered already statute-barred.
- Cases from 2018 where income tax returns were filed late during 2024, a circumstance that shifts the statute of limitations deadline to the end of 2026.
- Income tax cases from 2015 in which supplementary or new evidence has emerged — such as forged or fictitious invoices linked to tax evasion. For the ten-year statute of limitations to apply, the legal conditions must be met and the relevant tax amounts must exceed the prescribed thresholds. Deposits held in Greek banks are not, on their own, considered supplementary evidence, while transactions in foreign banks may, under certain conditions, be taken into account.
- VAT cases from 2015 where the required returns were never filed by professionals or businesses, making them subject to a ten-year statute of limitations expiring at the end of 2026.
- Cases from earlier tax years — such as the 2010 fiscal year — where no income tax return was ever filed, or where an initial return was submitted significantly late. In such instances, the tax authority’s power to assess taxes and impose penalties can extend up to 15 years, without exceeding that maximum limit.
